Don't Get Left Behind: A Turkey-Specific Model in the Management Process of Chemicals
Procedures and Principles Regarding the Implementation of KKDIK
The long-awaited Principles and Procedures Regarding the Implementation of KKDIK were published by the Turkish Ministry of Environment, Urbanization and Climate Change (MoEUCC) on 12th August, 2025. This document outlines essential details on how KKDIK (often referred to as Turkey REACH) will be implemented.
Key Takeaways
Pre-registration deadlines: All potential registrants must complete pre-registrations by 31 October 2025. For substances manufactured and/or imported for the first time after 31 October 2025, pre-registrations shall be submitted within 30 days of placing them on the market.
Lead Registrant (LR) selection: The Ministry has announced that LRs must be selected by 31 December 2025. For substances placed on the market for the first time after the publication of these principles and procedures, the LR must be selected within six months of market entry The LR candidate must inform other potential registrants and be approved by an absolute majority of those who respond within 30 days. If the LR candidate is not accepted by the absolute majority, the SIEF members are informed and the candidate withdraws from the lead registrant role, and the process for selecting a new lead registrant is initiated.
Role of the Union of Chambers and Commodity Exchanges (TOBB): If there is no volunteer company to act as Lead Registrant, the Ministry will initiate efforts to determine a company to act as Lead Registrant from among the manufacturers/importers of the substance to be registered, taking into account criteria such as tonnage band, available data and company size, and consulting with TOBB. TOBB will coordinate with the Ministry and industry organizations to manage joint registration groups and create standard contracts. A report on these activities must be submitted to the Ministry each December.
Data sharing: Once appointed, the LR must share the registration tonnage band, a data gap assessment plan and data sharing model with the potential registrants. The proposed plan requires approval from an absolute majority of potential registrants. If consensus is not reached, the LR will be replaced through a new selection process.
Temporary Registration: Lead Registrants may apply for temporary registration by submitting a basic set of information by 31 March 2026. Following the temporary registration of the LR, member registrants shall complete their submissions by 30 September 2026.
Extension Requests: If potential registrants are not able to provide the data by the relevant registration deadline due to data sharing issues, the LR may notify the MoEUCC and request an extension. The maximum extension granted will be 2 years from the relevant deadline. If data remains outstanding after this period, the Chemical Advisory Group will review the justifications provided. Subsequently, the Ministry will decide whether to approve or reject the registration for the substance
Time is of the essence. To ensure your business remains compliant with KKDIK, contact our dedicated team.
